Privacy Policy — SumiSketch

Strategia-X ("we," "us," or "our") operates the SumiSketch mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App. Please read this Privacy Policy carefully. By using the App, you agree to the collection and use of information in accordance with this policy.

Developer: Strategia-X / Rocky Stack
Package Name: com.sumisketch.app
Contact: [email protected]

1.1 Information You Provide Directly

SumiSketch is designed with privacy at its core. We do not require account creation, and we do not collect your name, email address, phone number, or any other personally identifiable information (PII) to use the App. Your artwork, projects, and drawing data are stored exclusively on your device and are never uploaded to our servers.

1.2 Information Collected Automatically

When you use the App, certain information may be collected automatically by third-party services integrated into the App:

• Device Information — Device model, operating system version, unique device identifiers (e.g., Android Advertising ID), screen resolution, and language settings.
• Usage Data — App interaction data such as features used, session duration, crash reports, and performance metrics.
• Network Information — IP address (which may be used to infer approximate geographic location at the city or region level), connection type (Wi-Fi or cellular).
• Advertising Data — Ad interaction data including impressions, clicks, and conversion events, collected by Google AdMob.

1.3 Purchase Information

If you subscribe to SumiSketch Pro, your purchase is processed entirely by the Google Play Store. We do not collect, process, or store your payment card details, billing address, or other financial information. Google provides us with a purchase token and subscription status to verify your Pro access. Please refer to Google's Privacy Policy for details on how they handle payment data.

1.4 Data We Do NOT Collect

The App does not collect, transmit, or store:

• Personal identification information (name, email, address, phone number)
• Your artwork, drawings, layers, or project files
• GPS location or location history
• Contacts, call logs, SMS messages, or communication data
• Photos, videos, or camera data (beyond what you explicitly import as reference images)
• Browsing history, search queries, or internet activity
• Passwords, credentials, PINs, or authentication data
• Biometric data
• Data from other applications

SumiSketch is a professional manga and illustration studio for Android built with Kotlin and Jetpack Compose. It provides 12 specialized brushes (Ink Pen, Cel Shader, Airbrush, Screentone, Watercolor, Eraser, Sparkle, Glow, Splatter, Chalk, Charcoal, and Marker), multi-layer canvas support (up to 10 layers), 18+ manga panel templates, pressure-sensitive stylus support, symmetry and perspective tools, speech bubbles, speed lines, timelapse recording, and project backup/restore (.sumi archives).

Minimum Android Version: Android 7.0 (API 24)
Target Android Version: Android 16 (API 36)

We use the automatically collected information for the following purposes:

• To provide, maintain, and improve the App's functionality and performance.
• To serve advertisements through Google AdMob (free tier users only).
• To verify subscription status for SumiSketch Pro users.
• To analyze usage patterns and improve user experience.
• To detect and prevent technical issues, crashes, and security vulnerabilities.
• To comply with legal obligations and enforce our Terms of Service.

The App integrates the following third-party services, each of which has its own privacy policy governing the data they collect:

4.1 Google AdMob

We use Google AdMob to display advertisements to free-tier users. AdMob may collect device identifiers, IP addresses, and usage data to serve personalized or non-personalized ads based on your preferences. You can opt out of personalized advertising through your device's ad settings (Settings > Google > Ads > Opt out of Ads Personalization). For more information, see Google's Privacy Policy.

4.2 Google Play Billing

Subscription purchases are handled by Google Play. We receive only a purchase verification token and subscription status. All payment processing is managed by Google. See Google Play's Terms of Service for more details.

4.3 Google User Messaging Platform (UMP)

We use Google's User Messaging Platform to present consent forms to users in jurisdictions that require consent for personalized advertising (e.g., the European Economic Area under GDPR). Your consent preferences are stored locally and respected by our advertising partners.

Your artwork, projects, layers, and preferences are stored locally on your device's internal storage using a Room (SQLite) database and Jetpack DataStore, protected by Android's application sandboxing. We do not transmit, upload, or back up your creative content to any server or cloud service. Project backup files (.sumi) are created and managed entirely on your device.

We implement commercially reasonable technical and organizational measures to protect the information collected through third-party services. However, no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.

Locally stored data (artwork, preferences, settings) remains on your device until you delete it or uninstall the App. Automatically collected analytics and advertising data is retained by our third-party service providers in accordance with their respective retention policies. We do not independently maintain databases of user data beyond what is stored locally on your device.

If you are located in the European Economic Area (EEA), you have the following rights under the General Data Protection Regulation (GDPR):

• Right of Access — You have the right to request information about the personal data we hold about you.
• Right to Rectification — You have the right to request correction of inaccurate personal data.
• Right to Erasure ("Right to Be Forgotten") — You have the right to request deletion of your personal data. Since we store data locally on your device, you can delete all data by uninstalling the App or clearing the App's data through your device settings.
• Right to Restriction of Processing — You have the right to request that we restrict the processing of your personal data.
• Right to Data Portability — You have the right to receive your personal data in a structured, commonly used format. Your artwork can be exported as PNG images or .sumi backup files directly from the App.
• Right to Object — You have the right to object to processing of your personal data, including for direct marketing purposes. You can opt out of personalized ads through your device settings.
• Right to Withdraw Consent — Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Our legal basis for processing personal data under GDPR includes: (a) your consent (for personalized advertising), (b) legitimate interests (for analytics and App improvement), and (c) performance of a contract (for subscription services). To exercise any of these rights, please contact us at [email protected].

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides you with the following rights:

• Right to Know — You have the right to request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purpose for collecting it, and the categories of third parties with whom we share it.
• Right to Delete — You have the right to request deletion of your personal information. You can delete all locally stored data by uninstalling the App or clearing App data in your device settings.
• Right to Correct — You have the right to request correction of inaccurate personal information.
• Right to Opt-Out of Sale/Sharing — You have the right to opt out of the "sale" or "sharing" of your personal information. We do not sell your personal information in the traditional sense. However, the use of advertising identifiers by AdMob may constitute "sharing" under CCPA/CPRA. You can opt out by disabling ad personalization in your device settings or by upgrading to SumiSketch Pro, which removes all advertising.
• Right to Limit Use of Sensitive Personal Information — We do not collect sensitive personal information as defined under CCPA/CPRA.
• Right to Non-Discrimination — We will not discriminate against you for exercising any of your CCPA/CPRA rights.

Categories of personal information we may collect (through third-party services): identifiers (device ID, advertising ID, IP address), internet or network activity (usage data, interaction data), and geolocation data (approximate, inferred from IP address). We collect this information for the business purposes described in Section 3.

To submit a verifiable consumer request, contact us at [email protected]. We will respond to your request within 45 days. You may designate an authorized agent to make a request on your behalf.

In accordance with CalOPPA, we agree to the following:

• Users can use our App without being required to provide personal information.
• This Privacy Policy is accessible from within the App and linked prior to or at the point of information collection.
• Our Privacy Policy link includes the word "Privacy" and can be easily found within the App.
• Users will be notified of any Privacy Policy changes through an update to this page and the "Last updated" date.
• Users can change their ad personalization preferences through their device settings.

Regarding Do Not Track (DNT) signals: We honor Do Not Track signals. When a DNT browser mechanism is in place, we will not serve personalized advertisements.

The App is not directed to children under the age of 13 (or under 16 in the EEA). We do not knowingly collect personally identifiable information from children under these ages. If we become aware that a child under 13 (or under 16 in the EEA) has provided us with personal information, we will take steps to delete such information. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at [email protected].

We configure our advertising services to comply with COPPA. Ads served to users identified as being under the applicable age threshold are non-personalized and comply with Google's child-directed treatment policies.

Information collected by third-party services (Google AdMob, Google Play) may be transferred to and processed in the United States or other countries outside your country of residence. These countries may have data protection laws that are different from the laws of your country. We rely on our third-party service providers' data transfer mechanisms (such as Standard Contractual Clauses) to ensure adequate protection of your data in accordance with applicable law.

The App itself does not use cookies. However, third-party services integrated into the App (such as Google AdMob) may use device identifiers, local storage, and similar technologies to collect information for advertising purposes. You can control these technologies through your device's privacy settings.

The App requests the following permissions. Each is used solely for the purpose described:

• INTERNET / ACCESS_NETWORK_STATE — Required for Google AdMob ad delivery and Google Play Billing subscription verification. No artwork or project data is transmitted over the network.
• VIBRATE — Used for haptic feedback on tool selections, gesture confirmations (QuickShape snap), and button presses.
• READ_EXTERNAL_STORAGE / READ_MEDIA_IMAGES — Required to import reference images from your device gallery. No files are transmitted off-device.
• WRITE_EXTERNAL_STORAGE — Required on older Android versions to export artwork (PNG) and project backups (.sumi) to shared storage.
• FOREGROUND_SERVICE — Required for timelapse recording to continue encoding when the app is briefly backgrounded.
• POST_NOTIFICATIONS — Required on Android 13+ to display export completion and auto-save notifications.

You can revoke any permission at any time through your device's Settings app. Revoking storage permissions will disable reference image import and artwork export but will not affect drawing tools, brushes, or saved projects.

In accordance with Google Play's Data Safety requirements:

• Data collected: Advertising identifiers and device information (collected by Google AdMob). Purchase tokens (collected by Google Play Billing).
• Data shared with third parties: Advertising data shared with Google AdMob only.
• Data handling is secure: All artwork and project data is stored locally within Android's application sandbox. Ad data uses encrypted connections.
• Data can be deleted: Users can delete all local data by clearing App storage or uninstalling. Exported files (PNG, .sumi) in shared storage must be deleted manually.

We may update this Privacy Policy from time to time. We will notify you of any material changes by updating the "Last updated" date at the top of this Privacy Policy and, where appropriate, providing additional notice within the App or on the Google Play Store listing. Your continued use of the App after any changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this Privacy Policy periodically.

This Privacy Policy shall be governed by and construed in accordance with the laws of the State of California, United States, without regard to its conflict of law provisions.

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Strategia-X
Email: [email protected]
General Inquiries: [email protected]
Website: strategia-x.com

For GDPR-related requests, please include "GDPR Request" in your email subject line. For CCPA/CPRA-related requests, please include "CCPA Request" in your email subject line. We will respond to all privacy-related inquiries within 30 days (45 days for CCPA requests).